Sanctions 2025

BELGIUM Trends and Developments Contributed by: Valerijus Ostrovskis, Bogdan Evtimov, Michael De Boeck and Coline Cauvin, ACQUIS

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Evolving Sanctions Landscape in Belgium and the EU Over the past year, the EU’s sanctions framework has continued to evolve in response to global geopolitical tensions, especially Russia’s ongoing war in Ukraine. Belgium, as an EU member state and home to key institutions such as Euroclear and the European Com - mission, plays a central role in shaping and imple - menting these measures. Between mid-2024 and mid- 2025, six new EU sanctions packages were adopted against Russia alone, each reinforcing sectoral bans and expanding asset freezes. The most recent, the 17th sanctions package, marked a further tightening of controls on advanced technology, dual-use goods, and transport networks used to circumvent restric - tions. Companies operating in or through Belgium must remain alert to these frequent regulatory shifts. The EU’s approach is increasingly focused on enforcement and closing loopholes, including through measures targeting the so-called shadow fleet, sanctions on insurers and logistics providers, and contractual obli - gations placed on EU exporters to prevent re-export to Russia via third countries. These developments demand heightened vigilance and compliance from EU-based businesses. A Stronger Enforcement Climate While EU sanctions were initially implemented with limited follow-up, recent years have seen a clear rise in enforcement actions. Belgian authorities have increased co-ordination between customs, the Min - istry of Finance, and the public prosecutor’s office. Notable actions include seizures of Russian dia - monds, timber, technology exports to Russia, and co- ordinated raids involving foreign intelligence services.

Although Belgian criminal court rulings remain unpub - lished, the volume of ongoing investigations indicates growing prosecutorial momentum. Belgium’s imple - mentation of the 2024 EU Directive on harmonising penalties for sanctions violations is expected to fur - ther strengthen the framework. Once transposed, this directive will introduce clearer rules on criminal liabil - ity, asset confiscation, and penalties for individuals and entities, bringing Belgium closer to the enforce - As enforcement tightens, the compliance burden on Belgian and EU companies is also increasing. Export - ers, banks, logistics operators, and professional ser - vice providers are expected to perform detailed due diligence not just on their clients, but also on partners in third countries. EU sanctions now place legal obli - gations on EU companies to take “best efforts” to pre - vent their subsidiaries and contractual partners from engaging in sanctions violations. This has a de facto extraterritorial effect, particularly in high-risk jurisdic - tions such as the UAE, Turkey, or Central Asia. ment standards of partners like the USA. Compliance Burden and Strategic Risk Companies are adjusting to these risks through inter - nal compliance programmes, legal reviews, and more cautious engagement with cross-border structures. Failure to do so can result in blocked payments, asset freezes, or regulatory investigations, even when the underlying transaction may not appear risky at first glance. Belgium’s Strategic Role and Exposure Belgium’s position as host to Euroclear, one of the largest international central securities depositories, places it at the centre of certain financial sanctions measures. The Belgian Ministry of Finance is the cru -

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